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Environmental impact assessment:

for whose needs?

J H Y Katima

ABSTRACT

Tanzania, like many other developing countries, is keen to attract foreign

investments to foster the countrys socioeconomic development. However,

the competition among developing countries to attract foreign investmentpreference has in many cases sacrificed policies geared towards sustainable

development for short-term economic gains. With the intention of

conserving the global environment, the multinational financing institutions

have made it mandatory that all development projects should be subjected

to EIA before they can be funded. Is this sustainable? This case study

suggests that an effective (and sustainable) EIA regime is dependent on,

among other things:

the governments political will;

effective environmental legislation;

institutional support; proper development objectives; and

trained personnel.

Unfortunately, many of these factors are not in place in Tanzania (and

probably not in place in most developing countries). This has led in many

cases to frustration on the part of environmental impact assessors,

governmental advisors and the public at large. Because of economic

considerations some projects have been given a go ahead despite negative

assessment and public outcry. In some cases, projects have been assessed

positively even though the negative impacts are obviously overwhelming,

which may be due to the fact that the investor is paying for the assessmentand thus may influence the outcome of the assessment process. This case

study examines the prawn project, which was subjected to EIA, rejected by

the review team and approved for implementation by the government. The

paper poses a question: For whose needs is the EIA conducted? The

investor? The government? The assessor? The environment? The public?

CaseStudy

19

See Topic 9

UNEP EIA Training

Resource Manual

Reviewing

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INTRODUCTION

The Rufiji River delta is the largest block of mangrove forest (mangroves) on

the eastern African coast. The delta is linked to the interior river system by

an extensive flood plain about 130km long and more than 20km wide. It is

also linked to a system of ocean currents and coral reefs.

The mangroves provide a unique ecosystem that displays dynamics of a

flood plain and delta system as expressed by changes in mud and silt

deposition, major fresh water outlets, and the creation of oxbow lakes, local

flooding patterns, salt water intrusion etc. The mangroves provide an inter

tidal fishery, serve as nursery grounds and breeding areas for the prawn

industry for the locals and produce large quantities of mangrove poles for

export.

Mangroves protect the coastline from waves and currents and thus prevent

coastal erosion. Through their retention of sediments brought downstream

by rivers, they extend the coastland into the ocean. As they are highly

productive elements of the marine ecosystem, mangroves generate large

quantities of detritus, which form the basis of a complex marine food web

thus making them a unique ecosystem that is rich in floral and fauna

biodiversity in both freshwater and saline environments. The delta has been

utilized over the years by the Rufiji people basically relying on fishing,

mangrove poles and rice farming for their sustenance. The present

population living in the delta is 35 000 people.

The African Fishing Company Ltd (AFC), a subsidiary of Tannol Holding

Ltd. of Korea, intends to develop a prawn farm covering about 6,000ha of

surface water, with grow out ponds on 10 000ha of land. The proposed

location of the prawn farm is within the Rufiji delta and the downstream

end of the flood plain. The proposed farm will consist of production ponds

plus water pumping stations, and supply and drainage canals. Staff

quarters, and storage facilities for the materials and supplies will be built

close to the farm. The target species for shrimp aquaculture is Penaeus

monodon. AFC plans to employ semi-intensive production methods at farm

level management.

The proposed development is planned to be accomplished in eight years

with the first year of operation targeted to build 500ha of ponds. The pondswill be of 6ha x 1m average depth in size. There will also be some smaller

ponds of the size of 0.1m x 1.0ha built for research and development

purposes. A hatchery is proposed at Bwenjuu Island in the Mafia Island

Marine Park where brood stock will be stocked at a density of 10 to 12

prawns per m2 and will be fed with feed meals. There will be 2.3 crops of

prawn per year with an annual production of about 2680 to 4600kg/ha. The

annual feed is estimated to be between 6624 and 8280kg/ha. The estimated

labour requirements are as follows: construction 250-500 people; farm

operation about 6000 people; the hatchery 500 people; at the processing

plant 1200 people. Other project components include:

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deep sea fishing in the Exclusive Economic Zone (EEZ) of the Tanzaniacoastal waters with a total fleet of six vessels;

the provision of fish meal plant at Mwanza to recycle waste from theprocessing units and a feed mill at Mbegani for production of feed stuff

from cereals and other unwanted fish and additives; and

the provision of training and education for personnel.NATURE AND SCOPE OF ISSUES

Policy and legal issues

In licensing the project the following pieces of legislation were contravened:

The National Land Policy of 1995 and Land Ordinance of 1923 were

contravened by transferring right of occupancy to the developer withoutrecognizing the customary rights of smallholders. The Forest Ordinance of

1997 and the Forest Ordinance Cap 389 of 1957 were contravened by

allowing the developer to establish the prawn farm in the forest reserve. All

mangrove forests are forest reserves. Allowing the developer to establish a

hatchery at Bwenjuu Island has violated the Marine-Park and Reserve Act

No. 29 of 1994. The project also falls within the licensed area to CANOP for

the purpose of oil exploration. Other legislation contravened includes: the

Water Utilization (Control and regulation) No. 110 of 1981 and international

conventions such as CITES Convention (because of the existence of two

endangered species in the area i.e. the Dugong and the Nile Crocodile) and

the Ramsar Convention (because the Delta is a contiguous wetland which is

part of the international landing sites for migratory birds). There also other

development projects within the area e.g. The Mangrove Management

Project, The Rufiji Delta and Floodplain Environmental Management and

Biodiversity Conservation of Forest, Woodland and Wetland, The Rufiji

Basin Management and Irrigation Project and The WWF Coastal Forest

Project.

Environmental issues

Loss of mangrove forest is estimated to be 1200ha. There is loss of

biodiversity in mangrove areas as a result of destruction of breeding sites

and nursery grounds for fish and other intertidal fauna, destruction of rare

species of mangroves such as Rhizophora, together with the threat to

endangered Dudong and Nile crocodile and over-exploitation of wild fish

stock by increased human population. Self generated pollution and

eutrophication in ponds, rivers and the ocean will come from effluents

containing antibiotics and toxic chemicals. Other impacts will be the

acidification and salinization of agricultural lands, disposal of wastes in

Kioboni and Bumba rivers and associated water borne diseases and

formation of complex land uses e.g. a town within the mangroves forest


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reserve and flood plain. There are no suitable soils within the reserve for

housing, sanitary landfill, oxidation ponds/lagoons, septic tanks etc.

Socio-cultural issues

The project will result in loss of agricultural land, displacement and

resettlement of local people, increased social conflicts between those who are

for the project and those against it, increased government costs for provision

of infrastructure and social services and changes in cultural values.

Economic issues

Calculations indicate that the project will make a net loss of US$ 24.9 million

in year one and a net forex gain of US$ 120 million in the fifth year.

However, the government has given a tax exemption and forex retention

holiday of 5 years, and the experience world-wide has shown that such

projects fail in their fifth year which means the government will not realize

anything. Using the overall risk of 30% the estimated foregone benefits in

Rufiji delta area ranges between US$ 72-107 million which exceeds the

adjusted income benefits of the project which is US$ 21 million.

Process and procedural context

Unfortunately, there is no legal requirement for EIA in Tanzania. There is

neither environmental policy nor environmental law. However, there is a

National Environmental Management Council which advises the

Government on environmental issues and the Division of Environment

under the Vice Presidents Office, which looks after policy issues. The

National Environmental Management Council has developed EIA

guidelines.

The Investment Promotion Centre has the sole responsibility of approving

all foreign projects. Its mandate is to assess economic viability. In this

particular case, maybe because of public pressure, the government required

an EIA before it approved the project. The developer had to produce an EIS

for evaluation. Furthermore, the developer intends to borrow money from

international financing bodies, in which case he has to show the

environmental impact of the proposed project.

The EIS was sent to the Environment Management Council for Evaluation.

The Council constituted a team of 11 experts, with three foreign experts

from the USA, Zimbabwe and Germany. The reviewers prepared a report,

and the NEMC also organized a public hearing, which drew participants

from the Rufiji people, experts in different fields, and politicians. Written

comments were received from within and outside the country. The

Councillors mostly represented the Rufiji people. Thirty-two participants

gave verbal comments on the project during the public hearing and 18

written comments were also read during the public hearing. The EIA review


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team raised numerous questions about the EIA and the recommended

mitigation measure. These views were supported in public hearings.

MITIGATION MEASURES

Mangrove forest

The EIA proposed a no-net loss of mangroves by suggesting that the project

replant mangroves in other areas. This was found to be unrealistic by the

review team as the mangrove species respond differently to ecological

requirements and other environmental factors and they are site-specific.

Also there are not enough bare saline areas or clear cut mangrove areas in

the Delta for replanting to compensate for the mangroves cut in the prawn

farm project. The project does not give alternatives to meet the objectives of

the mangrove management project. However, the EIA report admits theserious negative impacts of construction of canals, roads and other prawn

farm project activities.

Fisheries and marine environment

The EIA does not cite the fact that there are no alternative sites for hatchery

and grow out ponds. The EIA proposes that the use of DDT and antibiotics

should be minimized without suggesting alternatives and thus there was no

guarantee in the management submission in response to the EIA. The EIA

also reports that AFC is committed to implement the mitigation plan.

However, there are no funds budgeted to implement the plan. It was alsoobserved that unless there are screens at pump intakes there would be a

massive killing of fish and other aquatic zooplankton. Besides, there are no

funds set aside for this measure.

Land use

There are no mitigation plans to avoid a town growing in the mangrove

forest reserve. The septic tanks and/or oxidation pond necessary for the

treatment of domestic waste requires suitable soil, which is not available in

the delta. The ponds and other related structures will most likely be

inundated during spring tides at equinoxes. There is no mitigation plan forthis. There is a provision of 1m high levees above the surface which is not

enough to mitigate the inundation impact since the spring tides could be as

high as 1.5m.

Social benefits that are proposed for the locals who will be affected do not

have financial commitment. Nor are there funds set aside for resettlement of

the displaced families. No funds have been set aside set for land acquisition.

And finally there are no alternative sites for the project.


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Water resources

The drainage canals at the hatchery will be directed into small sedimentation

basins before discharging by an overflow into coastal waters; no treatment is

proposed. The EIA proposes, as a mitigation measure, that the pond

sediments be stored in specified areas and allows rainfall to leak in and

percolate to the ground. Also the EIA proposes that the pond sediments

could be used for road construction or other repair work. The review team

and the public hearing questioned the proposal because impact on ground

and surface water was not analyzed. There is no proposed mitigation

measure for an increase in waste matter, which will be disposed of in the

Kiomboni and Bumba rivers. The contamination of the two rivers by the

excessive use of lime will raise the pH of the rivers which serve as potable

water for the local residents.

Agriculture

No specific mitigation measure is proposed by the EIA despite the fact that

there is a possibility that polluted water from the prawn farm will leak into

agricultural fields.

Wildlife

The EIA does not look at alternative usage of the Delta e.g. wild life

protection for ecohunting and ecotourism. There are no mitigation measure

against possible poaching of Dugong and Nile Crocodiles, which are already

in alarmingly low numbers.

Socio-cultural

The EIA report uses cautionary words (non-committal) to address the

socioeconomic benefit of the project to the local people e.g. such words as

the proponent will support to a certain extent a dispensary, health centres,

schools and water. However, no financial commitment is made. The EIA

does not provide mitigation measures to cover the cost of displacing and

resettling people, costs of infrastructure and services for resettled people,

loss of boat tract in one of the sites, and the decline of food security through

the decline of agricultural land. However, the EIA proposes to discourageclearance of vegetation for agricultural purposes (i.e. after the project has

cleared thousands of hectares for ponds).

There will be increased hygiene risks through water borne diseases and

increased demand (with its environmental and social consequences) for fuel-

wood, drinking water, farmland and settlement areas. The EIA gives vague

statements such as insurance that local cultural pattern will be maintained.


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MONITORING PLAN

There were no comprehensive baseline studies done which could have been

used in the monitoring activity. The roles of the developer, the government,

local residents and other stakeholders are not clearly defined in the

monitoring plan. Besides this, monitoring activity is neither costed nor

budgeted for.

RESULTS AND IMPLICATIONS

The EIA review-team and the public hearing concluded that the EIA report

was highly biased in favour of the project. It was proposed that the project

be rejected on the following grounds:

The project is planned to be located in a Mangrove Forest Reserve and

Mafia Island Marine Park. Millions of dollars have already been spent

on both projects.

The plan is to discharge untreated effluents into the rivers that drain

into the Mafia channel and Bwenjuu Island reefs.

This will release untreated effluents containing silt, suspended solids

from the remains of feed and pond sediments, dissolved chemicals

from fertilizers, prawn feed, medicines (including antibiotics) and

other nutrients.

There are conflicts with existing and planned land use plans for theRufiji basin and Mafia Islands.

The proposal has many negative socioeconomic impacts on both the

vicinity of the proposed site and beyond.

The EIA is unsatisfactory, given so many uncertainties in the form of

the size of the project, the newness of technology that is expected to

be used and the relatively unknown baseline conditions.

The EIA, which looks very much like a polished project proposal, is

biased.

The Environment Management Council advised the government that:

The project should be rejected, and proper land-use plan and baseline

studies should be carried out in the Rufiji basin in order to harmonies

the various competing interests in the area.

A moratorium should be declared on all commercial mariculture in

Tanzania until the government establishes proper guidelines for the

development of commercial aquaculture in the country.


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Large scale aquaculture should not be conducted in ecologically

sensitive areas like mangroves.

The letter of offer allocating part of Bwejuu Island to the AFC shouldbe revoked, since this offer contravenes the National Policy (1995) and

the Mafia Island Management Plan and legislated under the Marine

Parks and Reserves Act No. 29 of 1994.

Against all these recommendations the government approved the project

without consulting the National Environment Management Council. In

whose needs was EIA carried out? That is the question.

LESSONS LEARNED

EIA can not have any meaning, unless there is a strong governmentcommitment in a form of a policy and environmental law.

Lack of awareness of the importance of avoiding unnecessary

environmental degradation hampers the success of the EIA regime.

As long as EIA remains the responsibility of the developer, objective

EIA will take time to come by. This leaves a loophole for influencing

the EIA in the proponents favour. Using experts from abroad is not a

solution; this is because the local experts know the local environment

better and they are the ones who have to perform the monitoring. In

these circumstances the use of foreign experts is not sustainable.

Lack of harmonized institutional arrangement with a clear and

properly co-ordinated flow of events guarantees a continued

contradiction in approval processes.

Financial institutions should not only be concerned with seeing EIA

reports but should also be interested to ensure that the

recommendations are implementable and that the local capacity to

monitor the implementation is in place.

Some funds, such as those of GEF, could be used to commission EIA

initially to ensure an unbiased report.


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LIST OF RELEVANT PUBLISHED PAPERS AND OTHER SOURCE

MATERIAL

Boyd C.E. 1996, Environmental Impact Statement for Ecologically-Responsible

Shrimp Farming Project in the Rufiji Delta, Tanzania, prepared for the African

Fishing Company Ltd. Dar es Salaam. 112pp.

Fottland, H. and Sorensen, C. 1996, Issues Related to the Establishment of Prawn

Farm in Tanzania with example from the Rufiji Delta, Catchment Forestry Report

96.4. Dar es salaam, October 1996, 35pp.

Hughes, R. 1996, Environmental Impact Statement for an Ecologically Responsible

Shrimp Farming Project in the Rufiji Delta, Tanzania: Some thoughts, review, Report

for Institute of Resource Assessment, University of Dar es Salaam, 5 September 1996.

Kerario, E.J.C., Mango, G.K., Nhwani, L.B., Dallu, A.M., Tibanyenda, R., Faraji, H.M.,

Ndimbo, M.M., Mungongo, C.G., Milne, G.R., Mitzlaff, U., Vergne P.J. 1997, Review

of EIA for an Environmentally-Responsible Prawn Farming in the Rufiji Delta,

Tanzania, prepared for the National Environment Management Council.

Ndimbo, E.K., Bwathondi, P.O.J., Mwasonja, G.J., Ntara, M.M., Wagner, G.M.,

Kabigumila, J. Chachage, C.S.L., Mvungi, A.A.K., Wagner, S., Boyd C.E., Scura, E.W.

and Massaut, L. 1997, An Environmentally Responsible Prawn Farming Project in the

Rufiji Delta, Tanzania, Vols I and II, April 1997.

United Republic of Tanzania 1994, Report on Existing Legislation Pertaining to

Environment, May 1994.

The author:

J H Y Katima

Department of Chemical & Process Engineering

University of Dar es Salaam

P.O. Box 35131

Dar es Salaam

TANZANIA

Key words

EIA process and

procedures

review

mitigation

decision

making


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